Smart labelling

Labelling is the first element of a cosmetic product that will make an impression on a consumer and plays a critical role in not only providing information about the product but also in promotion and engaging the consumer.

Article 19 of the Cosmetics Regulation defines all the mandatory requirements of labelling a cosmetic product. Whilst the legal requirements generally come from a safety perspective, the fact that labelling is also commonly used as a marketing tool cannot be ignored. Ultimately, the product label has potential to influence consumer purchase decision, and so it makes sense that brands/companies want to put as much information on their packs to give them a competitive advantage. The label is even more important in this sense for brands with less of an online presence.

However, whilst it is great to let your consumer know what active ingredients are in your product and what your product promises to do, it is important for brands to understand the regulatory impact of putting this extra information on pack. Certain elements of the label will need to be translated and depending on the size of the product and how many countries the product is being sold in, this may prove to be a challenge. To understand this further, let’s take a look at what is considered compulsory information to have on your label and what is additional.

What is mandatory according to article 19?

• Product function

• Warnings (as required by the safety assessment and any applicable ingredient warnings from the annexes to the regulation)

• Ingredient list

• Country of origin

• Net content

• Period after opening or best before date

• Name and Address of Responsible Person

• Batch code

What is not mandatory?

• Marketing text

• Additional (optional) warnings

• Recycling logos

• Company website

• Additional contact details (e.g. email/ contact telephone number)

From a regulatory perspective in the EU, translation requirements depend on individual laws of each member state however generally speaking, as a minimum, a member state will ask to be translate the product function and any mandatory warnings (as specified in the above list). However once additional marketing information is added, certain member states will also make this a mandatory requirement to translate this information. It is worth pointing out, some member states require equal prominence in their translations so you can’t always resort to putting the information on the back of pack or in a leaflet.

In order to save space on pack or avoid translations you may want to consider the following questions:

Are your warnings necessary? Only warnings required by the safety assessor/ warnings applicable to the product from the regulation annexes are mandatory to put on pack. Any additional warnings that do not need to be there can be removed to save space and save on translations.

Is your product function obvious? Where the product function is obvious from its appearance (e.g. a lipstick) a product function is not required to be present however again, if you do write this on your pack, it’ll be required to be translated. You can avoid this by use of logos (e.g. a picture of an eye on an eyeshadow pack).

Can you utilize a QR code? With more and more companies switching to digital means of sharing information, one space saving option could be to put a QR code on pack with a link to a webpage with translated marking text/ company information into the language of the MS you are marketing in. Although this option can't be used for the mandatory functions, warnings etc under the current legal text, it could be a useful way of avoiding putting extra marketing information that will need translating on your label.

Ultimately, the product label serves many functions and can be used advantageously by both regulatory and marketing departments. With more and more brands opting for minimalist labels, the options discussed could be a great way to ensure your product is compliant whilst prioritising the aesthetic of your brand.

If you need additional help on translation requirements or saving space on your label, please contact us at info@bloomregulatory.com

Laila Manshi